Waiters v. State
210 So. 3d 209
| Fla. Dist. Ct. App. | 2016Background
- Defendant Danny Waiters, age 17 at the time of the offense, was convicted of second-degree murder and sentenced to 40 years' imprisonment.
- Waiters moved to correct his sentence, arguing Horsley v. State entitled him to resentencing under Fla. Stat. § 921.1402 (2014) despite his crime predating the statute's effective date.
- Horsley held that § 921.1402 applies to all juvenile offenders whose sentences are unconstitutional under Miller v. Alabama.
- Miller prohibits mandatory life-without-parole sentences for juvenile homicide offenders; Horsley and subsequent Florida cases address which juvenile sentences are "unconstitutional under Miller."
- The trial court denied relief; the appellate court affirmed, finding Waiters did not receive a mandatory life-without-parole sentence nor a de facto life-without-parole sentence requiring Miller relief.
- Judge Kelly concurred in result but would have reversed, stressing Florida Supreme Court precedent emphasizing individualized juvenile sentencing and review mechanisms.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 921.1402 applies to Waiters though his crime preceded the statute | Waiters: Horsley requires juvenile offenders with Miller-unconstitutional sentences to be resentenced under § 921.1402 regardless of crime date | State: Horsley only applies to juveniles whose sentences are unconstitutional under Miller (i.e., mandatory life-without-parole); Waiters’ 40-year term is not such a sentence | Affirmed: § 921.1402 does not apply because Waiters did not receive a mandatory or de facto life-without-parole sentence under Miller |
| Whether a lengthy term of years (40 years) equates to a de facto life-without-parole requiring Miller relief | Waiters: A long fixed term without individualized juvenile sentencing or review can be unconstitutional in spirit of Miller/Horsley | State: A 40-year term is not equivalent to life without parole and does not trigger Miller relief | Affirmed: 40-year sentence is not de facto life without parole; no Miller-based relief warranted |
Key Cases Cited
- Horsley v. State, 160 So.3d 393 (Fla. 2015) (held § 921.1402 applies to juvenile offenders with sentences unconstitutional under Miller)
- Miller v. Alabama, 567 U.S. 460 (2012) (mandatory life-without-parole for juveniles convicted of homicide is unconstitutional)
- Graham v. Florida, 560 U.S. 48 (2010) (life without parole for juvenile nonhomicide offenders unconstitutional)
- Landrum v. State, 192 So.3d 459 (Fla. 2016) (reversed nonmandatory life-without-parole sentence imposed without individualized consideration of youth)
- Henry v. State, 175 So.3d 675 (Fla. 2015) (court looks beyond label of sentence to practical implications for juveniles)
- Atwell v. State, 197 So.3d 1040 (Fla. 2016) (Florida Supreme Court endorses examining practical implications of juvenile sentences rather than a narrow textual approach)
- Williams v. State, 197 So.3d 569 (Fla. 2d DCA 2016) (held a 50-year sentence is not equivalent to a life-without-parole sentence)